With reference to Article 10 (Dividends a) In the case of Chile, because of its integrated, two-level income tax on business profits (First Category Tax and Additional Tax), the provisions of paragraphs 2, 3, 7, and 8 of Article 10 (Dividends) shall not limit the application of the Additional Tax provided that under the domestic law of Chile the First Category Tax is fully creditable in computing the amount of Additional Tax to be paid.
With reference to Article 10 (Dividends. The provisions of Article 10 shall not apply in the case of distributions or dividends paid by an enterprise when the investment is subject to a foreign investment contract under the Foreign Investment Statute (DL 600), as it may be amended from time to time without changing the general principles thereof.
With reference to Article 10 (Dividends. It is agreed that if any agreement between the Republic of Tajikistan and one of the current (as of the date of signature of this Protocol) member states of the Organisation for Economic Co-operation and Development signed after the date of signature of this Agreement provides that dividends paid by a company resident in Tajikistan shall be exempted or taxed in Tajikistan at a lower rate than that which applies by virtue of paragraph 2 of Article 10, then such exemption or lower rate shall automatically apply to dividends governed by that paragraph. In such case, it is further understood that the competent authority of Tajikistan will inform the competent authority of the United Kingdom without delay that the conditions for the application of this paragraph have been met.
